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1. Overview

Welcome to 91����! We value the trust you place in us when providing us with your Personal Data, and we aim to protect your data to the highest of standards as we provide our products and services to you. This Privacy Policy was last updated on 22 January 2025.

View the archived versions here

2. Scope of this policy

This Privacy Policy describes how we process the Personal Data of our existing and prospective customers, end-users who use or request our Services, visitors of our websites, vendors, partners, and those who participate in our promotions or events (‘��dz�’&�Բ�����;or ‘your‘). It also describes your data protection rights, including your right to object to some of the processing activities which we carry out.

This policy applies to all Personal Data that we collect, use, or disclose when providing our websites, platforms, apps, products, and services owned or operated by us.

What ‘Services’ does this Privacy Policy apply to?

Services	Features + Description
EH Platform	HR and payroll platform, including features like Hero Passport and Perks.
EH Work app	The 91���� app including the HR features of the EH Platform under its Work feature, along with financial products and services under the Money feature, and special offers, discounts and cashbacks under the Perks feature.
EH Jobs	91���� Job board (EH Jobs board), the 91���� Jobs app (EH Jobs app), and catered Recruitment Services. These are services that can only be accessed if you separately sign up for them.
Employer of Record (EoR) service	Our Employer of Record (EOR) services.
HR Advisory	HR advice and support services.
Implementations services	Services that provide smooth onboarding onto our platform for our business customers. Employers will provide us with relevant HR and payroll data relating to their employees for the implementation process.

Our Services include “AI Services” that supercharge your experience and allow us to deliver our products with streamlined processes and efficiency. We incorporate our AI Services with transparency ensuring you have full visibility into the functionalities and benefits they bring. To find out more, you can view our AI Services Statement.

We treat your Personal Data with the utmost care and in compliance with the applicable data protection laws. We may also provide you with additional information when we collect Personal Data where we feel it would be helpful to provide relevant and timely information.

This Privacy Policy does not apply to the following.

• Personal Data processed under the instruction of business customers – this Privacy Policy outlines our independent data processing practices as a data controller, including joint-controller responsibilities. It also covers Personal Data submitted by you or your organisation for processing on your behalf, like payroll data, demographic information, and employment details. For details on our role as a data processor under your instructions, refer to our Data Processing Addendum. 
• As an employer – any Personal Data we process as a prospective, current, or former employer. If you are applying for a role with us or our affiliates, please refer to our Applicant Privacy Policy.
• Third-party data – any products, services, websites or content that are offered by third parties through integrations with our Services, which are governed by their own privacy practices.

3. Who are we

When we say ‘91����’, ‘us’, ‘our’, or ‘we’ in this Privacy Policy, we’re referring to 91���� Pty Ltd and its affiliates.

4. Personal Data

Data classification	Description
Personal Data	Personal Data (also known as “Personal Information”) is any information relating to an identified or identifiable natural person, i.e. one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
Special Categories of Personal Data	Special Categories of Personal Data (also known as “Sensitive Information”) include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

If you cannot be identified, then this notice does not apply to you. An example of this is when your Personal Data has been aggregated and/or anonymised.

5. Types of information that we collect

The Personal Data we collect and process will vary depending on your dealings with us and the Services we provide to you.

We may also collect and process Special Categories of Personal Data with your explicit consent when providing our Services to you, which includes Special Categories of Personal Data submitted by you, or on your behalf, through our Services.

Personal Data we collect	Relevant Services
Individual account information including name, username, date of birth and age, details regarding gender, sex, marital status, profile photo, and login credentials	• EH Platform • EH Work app • EH Jobs • Employer of Record (EoR) service
Individual contact information including residential and/or postal address, email address, telephone number, emergency contact information, and social media handles	• EH Platform • EH Work app • EH Jobs • Employer of Record (EoR) service
Business contact information including administrator and account owner names, signatures, information about the company’s employees (if provided), and the name and contact details of any personnel involved in the recruitment process	• EH Platform • EH Work app • Employer of Record (EoR) service
Employment related information including occupation or job title, information relating to your current employer, information relating to your former employer and role, key dates relating to your current role and/or past roles, superannuation information, salary and/or pension details including documents such as payslips and payment summaries, citizenship and visa status for work eligibility purposes, and tax information	• EH Platform – Hero Passport • EH Work app – Work feature – Hero Passport • EH Jobs • Employer of Record (EoR) service
Employment performance information including workplace engagement information, and performance reviews	• Employer of Record (EoR) service
Recruitment information including CV, cover letter, profile photo, videos you upload, work preferences, salary expectations, education history, work history, qualifications, languages, references (if you are applying for a role with 91���� or our affiliates, please refer to our Applicant Privacy Policy)	• EH Jobs • Employer of Record (EoR) service
ID verification and credit report information including government-issued identification documents such as passport and driver’s licence to comply with global anti-money laundering (AML), know your customer (KYC) and know your business (KYB) obligations	• EH Platform • EH Work app – Money feature • EH Jobs • Employer of Record (EoR) service
Location information including specific location information you provide us via your device using GPS, wireless, or Bluetooth technology, including IP addresses and information about your internet service provider, computer and device information like device, application, or browser type and version, and location information you manually input (you can control access to precise location information through your device settings)	• EH Platform • EH Work app • EH Jobs • Employer of Record (EoR) service
Billing information including payment details such as banking, or debit/credit card details	• EH Platform • EH Work app – Money and Perks feature • Employer of Record (EoR) service
Special Categories of Personal Data including health or disability information, biometric information, immigration information, criminal history and background checks, and certain diversity related information	• EH Work app – Money feature • EH Jobs • Employer of Record (EoR) service Only as necessary and with consent.

6. How we collect your information

We may collect Personal Data through our Services provided to you, or through other means when we engage with you or third-parties. 

• Through the Services and sign-up process – we collect the information you provide to us when you do things like request, sign up for and use our Services, update your user profile, or voluntarily engage with us in other ways through the Services.
• General interactions with us – we collect information when you interact with us, such as when you use our communicate with us via email, telephone, SMS, video conference, social media or chatbots, make enquiries regarding demos, attend or participate in our events or promotions, or when we collect feedback from you on the Services we provide. The information we may collect in these circumstances include your name, business name, address, email, phone number, company/employer information, job function, team size, reason for contacting us, survey and research responses, social media information, and video and call recordings.
• Automatic collection – we automatically collect usage information when you browse our websites or use our Services to improve our Services and enhance your user experience. This information includes digital interactions data, i.e., how you use our digital properties (including our websites, third-party websites, social media sites, apps and electronic communications), metadata (collected on an anonymous basis), consumer analytic data (collected on an anonymous basis but which can be attributed to you based on other information we have about you), log file information, information about the type of device and operating system used by you, location information, device IP addresses, and marketing and cookie preferences, including any consent you have given us.
• General collection from third-parties – we may collect your Personal Data from third parties where you have provided consent, or where such Personal Data is provided to us under a legal basis. This includes situations where an employer provides information about employees through our platforms or apps. This also includes situations where Personal Data is collected through third-party APIs, or by third party service providers, including providers who support automatic collection as mentioned above, social media sites who are permitted to disclose that information to us under a legal basis, or to support our delivery of Services or direct marketing activities. We may also collect Personal Data about you through our affiliates.
• Service-specific collection from third-parties – we may collect Personal Data about you in the process of providing our Services to you from third parties who also engage with that Service.
  • Employer of Record (EoR) service: if you are an individual employed through our Employer of Record (EoR) services, we may collect Personal Data from the party that has engaged us as a Employer of Record (EoR) services customer;
  • Applicant Tracking System (ATS): if you are a user of a third-party job application platform which integrates with our ATS, we may collect Personal Data about you that is processed through our ATS as provided via the third party platform; and
  • Super Services: if you are based in Australia, we may receive Personal Data about you from your superannuation fund when verifying your membership with them if we are providing our superannuation services and features (Super Services) to you upon your request.
• HR Advisory – if you access our HR Advisory services to receive advice and support, and/or non-court representation, we may collect information about you from any third party that supports us in providing you this service (to the extent that no legal privilege is breached). 
• Google APIs – we may receive Personal Data via Google APIs. Our use of Persona Data received from Google APIs will adhere to the , including the Limited Use requirements.
• Google reCaptcha – we have implemented Google reCAPTCHA Enterprise on certain products and services to prevent malicious software from engaging in abusive activities on our Services. Your use of reCAPTCHA Enterprise is subject to Google’s and .
• Google Analytics – we may use Google Analytics to obtain certain analytics information regarding your interactions with our Services. You may opt-out from the Google Analytics service using your information by installing the .
• Digital payment providers – you can use the Swag debit card with digital payment providers via your device, and there may be instances where we collect Personal Data from these digital payment providers for fraud prevention and identity verification purposes. You can view our digital payment terms here.

Information we collect from you about third parties

From time to time, you may provide us, and we may collect from you, Personal Data of or about a third party (for example, information you put into our systems as an employer on behalf of your employees). When you provide the Personal Data of a third party, it is your responsibility to ensure that the necessary consent has been acquired or other lawful basis is relied on, and that those individuals are aware of this Privacy Policy, and that they understand it and agree to accept it.

7. Why we process your information

The legal basis we may rely on when processing Personal Data

We must have a legal basis to process your Personal Data and we explain these legal bases below.

• Contractual performance – we have obligations under our contract with you. To fulfil those obligations, we will have to use your data.
• Consent – in certain cases, we ask for your consent to use your data. Whenever we ask for your consent, we will explain the situations where we use your data, and the purposes for which the data will be used.
• Legitimate interest – we can process your data when this is necessary for us to achieve a business purpose, or where this is necessary for someone else to achieve their purpose. We explain below what interests we, or others, are trying to achieve when we process your data. Where we process Personal Data on the basis of a legitimate interest, then to the extent required by data protection law, we carry out a balancing test to document our interests, to consider what the impact of the processing will be on individuals, and to determine whether individuals’ interests outweigh our interests in the processing activity taking place.
• Legal obligation – as an organisation, we are obliged to comply with applicable legal and regulatory requirements. In certain cases, we will have to use your Personal Data to meet these obligations.

Purposes for processing Personal Data

In the table below, we have explained the reasons for which we process your Personal Data, the processing activity that we carry out, the legal basis that applies in each instance, and the categories of data that we use for such activities.

What We Do And Why	Legal Basis	Personal Data
Fulfilling our contract, or taking steps linked to our contractual obligations	Contractual performance, consent	Any types of data identified as is necessary for this purpose
Providing implementations services to implement our products and services for you, and onboard you on to our platform	Contractual performance, consent	Individual account information, Individual contact information, Employment related information
Providing our Services, including ancillary Services such as customer support and implementations	Contractual performance, consent	Any types of data identified as is necessary for this purpose
Processing payments for our Services	Contractual performance	Billing information
Storing payment history information	Legal obligation	Billing information
Sending direct marketing	Consent, legitimate interest	Individual account information, Individual contact information, Business contact information, Employment related information
Reporting on marketing campaign activities and understanding effectiveness of the campaigns	Legitimate interest, consent	Individual account information, Individual contact information, Business contact information, Employment related information
Conducting surveys and other market research to ensure our Services are relevant to your needs	Consent, legitimate interest	Individual account information, Individual contact information, Business contact information, Employment related information
Managing our use of tracking technologies such as cookies and analysing collected data to learn about our Services	Consent	Device data and data relating to the usage of Services
Sending service, technical and other administrative messages relating to our Services	Contractual performance, legitimate interest	Individual account information, Individual contact information, Employment related information
Ensuring Services are working as intended, and tracking outages or troubleshooting issues	Contractual performance	Data relating to the usage of Services
Personalising your experience with the Services, and tailoring our communications and marketing to you	Legitimate interest, consent, contractual performance	Individual account information, Employment related information, Location information, Search function inputs
Aggregating anonymised salary data for the purpose of salary benchmarking in various industries and geographies	Legitimate interest	Employment related information (aggregated and anonymised salary data)
Investigating any complaints by or about you	Legitimate interest	Any types of data identified as is necessary for this purpose
Investigating, raising or defending ourselves from legal claims	Legitimate interest, legal obligation	Any types of data identified as is necessary for this purpose
Investigating any suspected breach of any of our terms and conditions or unlawful activity engaged in by you	Legal obligation	Any types of data identified as is necessary for this purpose
Responding to legal matters, including court orders, subpoenas, or other legal processes	Legal obligation	Any types of data identified as is necessary for this purpose
Complying with our compliance, regulatory, auditing, and investigative obligations (including disclosure of such information in connection with legal process or litigation)	Legal obligation	Any types of data identified as is necessary for this purpose
Verifying your identity and/or carrying out credit report checks, and enabling us to monitor suspicious or fraudulent activity	Consent, legal obligation	ID verification and credit report information, Special Categories of Personal Data
Assessing data to protect the security of our premises, assets, systems, and intellectual property, and to enforce company policies, including monitoring communications as permitted by law	Legal obligation, legitimate interest	Any types of data identified as is necessary for this purpose
Processing data when undertaking mergers, acquisitions, reorganisations, or disposals, as permitted/required in accordance with applicable law	Legitimate interest, legal obligations	Any types of data identified as is necessary for this purpose

Use of non-personal data to improve and develop products and models

We do not use Personal Data to train any AI models or for machine learning. We may analyse data relating to your activity and engagement on our Services to improve and develop our products, services, algorithms and models using machine learning. We may also analyse the performance of our Services to do things like optimise the product design, and develop and improve our products and services (including in relation to our engineering prompts used for our AI Enhancements).

Direct marketing and other communications

When we send you direct marketing based on our legitimate interests or where you have provided us with consent, these communications may be sent in various forms, including email, SMS, or social media. 

You have a right to opt out of direct marketing at any time. You can do this by following the instructions in the communication within the electronic message we send to you, or by contacting us via email at privacy@employmenthero.com. Outside of such direct marketing, you may receive push notifications on your device, which can be controlled by your device settings. 

We may also send you system trigger notifications about your use of the Services that you may be able to turn off using the preference settings within the platform. 

We will still send you important notices relating to your account, operational activities, and technical updates, even after you have opted out of receiving direct marketing communications. 

Phone numbers, emails, and opt-in consents will not be shared to third parties for their marketing purposes without your consent. 

Cookies and tracking technologies

The Services we provide use cookies and similar technologies on our platform, app and websites. Cookies are small text files containing a string of alphanumeric characters which are sent to your computer that uniquely identifies your browser and lets us enhance your experience when using our Services. Cookies also convey information to us about how you use our Services.

When you use our Services, we may use cookies and similar technologies for the purpose of authenticating your use, remembering your preferences and settings, determining the popularity of content, and analysing and understanding your interactions with our Services.

The information that may be recorded includes information regarding your:

• server address;
• domain name;
• date and time of visit;
• previous websites visited;
• use of our sites; and
• browser type.

You can also read our Cookie Policy to further understand how cookies and similar technologies may be used to collect and use your Personal Data.

8. How we share your Personal Data

Sharing of information when providing our Services

We may share your Personal Data with our affiliates and with other third parties from time to time for the purposes and means described in this Privacy Policy. We may disclose your information to:

• Members and personnel of the 91���� group – we may share your information between our affiliates and business functions, including with our employees, contractors and representatives for the purposes of the delivery and operation of our Services, and fulfilling requests by you;
• Vendors who support the delivery of our Services – we may disclose your Personal Data (including via APIs) to specific third-party service providers who facilitate the delivery of our Services, including the implementation of our Services. These third parties are given access to your Personal Data only to perform these tasks on our behalf or for our benefit, and are required not to use or disclose it for any other purpose;
• Third party service providers – we may disclose your Personal Data to third parties who provide services, software, and content made available for use on or through our Services (including add-ons and integrated services);
• Web browser extensions providers – our sharing of your Personal Data with third parties may occur through the use of verified web browser extensions. These web browser extensions will only be used by the business if it is developed by the third party provider of the standard version of that product or service;
• Legal and regulatory authorities – we may share your information with legal, regulatory or government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws, and we will notify you of such disclosure requirement to the extent permitted by law or regulation;
• Parties involved in a business sale – in the event that we undergo any reorganisation, restructuring, acquisition, merger, sale, or other transfer of assets with another entity, including any due diligence activity carried out in connection with such events, then your information may be disclosed to our advisers, any prospective purchaser’s advisers, and the other entity, as needed to complete the transaction, and to meet the purposes set out in this Privacy Policy;
• Event or promotion partners – we may share your data with event or promotion partners if you participate or show interest in such event or promotion;
• Business partners – we may share your data with our existing or potential agents, business partners, or joint venture entities to enable us to perform our business activities in relation to our services; and
• Your organisation – where you are an employee of one of our customers, we may share your information with your employer and other personnel in your organisation (where it is necessary and reasonable).

Sharing of information specific to our EH Jobs, including EH Jobs app and EH Jobs board, and any additional Recruitment Services

EH Jobs app and EH Jobs board

EH Jobs facilitates the connection between businesses and candidates to host the recruitment process and help businesses attract talent. In providing this service, we share the Personal Data you provide in your EH Jobs profile and/or job application with businesses if you are a candidate under this service.

If you have a public profile, your profile and data is viewable by business customers using EH Jobs. We may further share your profile and data with any other businesses you choose to express interest in or apply for through EH Jobs. 

We also share the contact details of the hiring manager of the business to candidates if it is provided by the business when using the features of this service.

You can also learn more about EH Jobs by reading our EH Jobs – SmartMatch Product Statement.

Recruitment Services

To provide this service, we advertise job openings for business customers and share candidate Personal Data with such customers to recruit talent for them. If you are a business customer that has subscribed to receive our off-platform Recruitment Services to recruit talent for a job in your business, we may share your business contact information with such candidates.

Sharing of information specific to Employer of Record (EoR) service

To provide our Employer of Record (EoR) service services, we act as the employer of record for employees who offer their skills and services to our customers. To provide this service and facilitate the relationship between our customer and the employee, we may share Personal Data of each party with the other, or with partners who support us in providing this service. This means that if you are a customer under this service, we may share your Personal Data with the employee, and if you are an employee under this service, we may share your Personal Data with the customer or relevant partner.

Sharing of information with superannuation funds when providing our Super Services (Australian customers/users)

In connection with providing our Super Services, we may share your relevant Personal Data with our partner superannuation funds to check your membership with them (provided that you have given us consent to disclose your Personal Data to the superannuation funds). Once we verify you as a member of a superannuation fund, we will continue sharing your Personal Data with your chosen superannuation fund (including changes to your personal details, employment changes, life event information and other matters) only in connection with providing you access to their services and delivering our Super Services to you.

Sharing of your information specific to the Swag Spend Account

We may share your Personal Data with our payment partners if you apply for non-cash payment products that they issue. If we, or the payment partners, share your data with third party organisations (including those based in the US and UK) for the purpose of providing risk assessments and transaction monitoring (PEP and sanctions checking), it will only be related to the provision of the product provided by us via the EH Work app that contains the spend account and Swag debit card (Swag Spend Account). We also share your Personal Data with third parties to verify your identity for the purposes of providing you with a Swag Spend Account.

Sharing of your information specific to HR Advisory

We may share your Personal Data with partners, including affiliate entities, that directly support the provision of the HR Advisory services strictly for the purpose of providing the service. When doing so, we will make sure you are aware of the other parties involved and the role they play in providing the HR Advisory service.

9. International data transfers

We may disclose Personal Data outside of the country in which our customers and users are based in connection with the purposes identified in this Privacy Policy, and the Services described. International data transfers may occur when we share Personal Data with 91����’s team members and affiliates based globally, including in Australia, United Kingdom, New Zealand, Singapore, Malaysia, Vietnam, and the Philippines and other locations from which the team members may work remotely. International data transfers may also occur when we share Personal Data with third party service providers located globally where it is deemed reasonably necessary for us to make such transfers.

We take measures to ensure that international data transfers take place in compliance with applicable laws relating to international data transfers and in accordance with at least the standards that apply in the country whose privacy or data protection laws apply to that Personal Data. If you are a EEA or UK customer or user of our Services, your Personal Data is transferred outside the EEA or the UK in compliance with the relevant requirements under the GDPR.

Adequacy decisions

Where the European Commission or the UK government has determined that certain countries outside of the EEA or the UK have an adequate level of Personal Data protection, e.g., New Zealand, Personal Data can be transferred to such a country from the EEA or UK without any further safeguards being necessary. A full list of such adequate countries is available  (for the EEA) and  (for the UK).

Where information is transferred outside the UK, or the EEA to a location that is not subject to an adequacy decision by the European Commission or the UK government, we ensure data is adequately protected. We may transfer your Personal Data (as described in section 5 above) for the purposes described in section 7 above to another country by relying on the  for the transfers from the EU, or the  or  for the transfers from the UK, or relying on such other data transfer mechanisms as available under applicable data protection laws.

A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

10. Third-party links

The Services may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website. Third-party websites are responsible for informing you about their own privacy practices and policies and you are encouraged to review the privacy notices.

11. Storage and security of Personal Data

Personal Data held by us will be stored and managed on secure data centres in Australia, Ireland and Canada by our third-party storage provider. Further details on our third-party storage provider’s location and security can be .

Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Data we have collected from you.

You can also play an important role in keeping your Personal Data secure by maintaining the confidentiality of any password and accounts used on the Services. Please notify us immediately if there is any unauthorised use of your account by any other internet user, or any other breach of security relating to your account via email at privacy@employmenthero.com.

You can learn more about how we keep your Personal Data secure by visiting our .

12. Data retention

We retain data for as long as necessary to provide our Services and in accordance with our internal Data Retention Policy. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. We may delete (or anonymise) your Personal Data once this data is no longer needed for us to provide our Services to you, and this data will not be retrievable in the future once deleted.

You can delete some data whenever you like, some data is deleted automatically, and some data we retain for longer periods of time.

For example:

• We keep account information for as long as your subscription or agreement continues or for as long as it is necessary to deliver our Services.
• We will keep a record of the fact that you have asked us not to send you direct marketing, so that we can respect your request in future. If you unsubscribe from receiving direct marketing, then we will remove your details from our direct marketing mailing list.
• We will keep the usage information and analytics data relating to your use of the Services to understand how people use our Services. We will do this through the use of cookies and tracking technologies to provide us with user analytics data to improve our Services and enhance your user experience. More information about the retention period of cookies can be found in our Cookie Policy.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, and for an extended period of time. Reasons we might retain some data for longer periods of time include security, fraud prevention, financial record-keeping, complying with legal or regulatory requirements, ensuring the continuity of our Services, and when you have had direct communications with us.

13. Your rights and choices

You can also object to the processing of your Personal Data in some circumstances where it is practicable to do so, i.e., when we are using the data for direct marketing.

These rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.

For the provision of information marked as mandatory when you register to use our Service, if such information is not provided, then you will not be able to use our Services. All other provision of your information is optional. If you do not provide such information, our provision of certain Services to you may be detracted from.

Where we rely on your consent, such as in relation to direct marketing communications, you will always be able to withdraw that consent at any time.

If you withdraw your consent to our processing of your data, this will not affect any processing which has already taken place.

14. How to get in touch with us

If you have any questions or concerns about how we process your data, please contact us via email at privacy@employmenthero.com.

We have appointed a Data Protection Officer (DPO) in the UK and Singapore, and a representative in the EU. If you wish to contact them about our privacy practices in these jurisdictions, you may do so using the contact details provided below.

Appointment	Details
Data Protection Officer	• Name: Bird & Bird DPO Service SRL • Email: dpo.employmenthero@twobirds.com • Address: Avenue Louise 235 b 1, 1050 Brussels, Belgium
EU Representative	• Name: Bird & Bird GDPR Representative Services Ireland • Email: eurepresentative.employmenthero@twobirds.com • Address: Deloitte House, 29 Earlsfort Terrace, Dublin 2, D02 AY28

15. Enforcement and complaints

If you have a complaint regarding this Privacy Policy or any breach of applicable data protections laws, please contact us in accordance with section 14 above. Once we receive a complaint, we will commence an investigation as soon as practicable. We may contact you during the process to seek any further clarification if necessary. We may also contact you to inform you of the outcome of the investigation.

We will aim to ensure that all questions and concerns are resolved in a timely and appropriate manner. If you are not satisfied with the outcome of your complaint, or require further information on privacy, you are entitled to contact your local data protection supervisory authority.

16. Changes to our Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time to reflect changes in the laws or regulations, our practices, our Services, or our operational requirements. You may periodically review this Privacy Policy to stay up to date with the latest changes. In the event that we make any significant changes in terms of data processing operations or any other change that may be relevant to you or impact you, we may additionally notify you via email or in-platform notifications on our Services.

17. Related policies

Data Processing Addendum

Applicant Privacy Policy